Quote from: firefop on July 07, 2013, 11:41:29 PM

I should point out that there are no administrators since the requirement states they be able to both issue and redeem (withdraw from circulation) --- nobody can withdraw a bitcoin from circulation - so we have no administrators.

so the only thing at applies is "as a business" re: exchange of bitcoin to fiat or vice versa.

So miners and users don't need to concern themselves - only exchanges and people who are registered as a business...

99% correct - green is statement on point. red is not so on point.
miners making bitcoin are fine. but mining pools such as 50BTC.com which allows withdrawals in FIAT at the pool. have to be careful.
mining 'workers' dont need to be concerned but pools offering FIAT(direct bank transfer)/convertible virtual currency (dwolla /webmoney online representation of FIAT) Do need to be careful

anything touching FIAT has to be careful. fincen rules are all about dollars and always have been.

the words
Convertible virtual currency - is not bitcoin. so bitcoin remains unaffected just like the last 4 years.

convertible virtual currency = a database on a server(not owned by the banking sector) with a numeric amount that represents a FIAT value.

EG bitstamp dollar is not a legal tender dollar as its only viewable on bitstamp servers. so this is the convertible virtual currency.

bank account dollar is legal tender. so when bitstamp convert their online balance into someones bank account they need to be registerd as a MSB and regulated(licenced) for money transmission because they are moving legal tender aswell as convertible virtual currency.

for a mining pool owner just moving dwolla balances from his dwolla account to his mining workers dwolla accounts. he just needs to be a MSB registered but not money transmission licenced, due to the fact that they are not moving legal tender. only convertible virtual currency (dwolla dollars). so no money transmission licence.(because they dont touch BANK accounts of customers)

the simple rule is. if your moving FIAT around or handling the online digital form of it AS A BUSINESS you need to be MSB registered. if you are then doing specific things like moving it into bank accounts (legal tender) then you need money transmitter licences ontop.